- 2 - disallowance of petitioner’s passthrough Marc losses pursuant to section 1366(d).1 The issue for decision is the amount of petitioner’s adjusted basis in Marc as of December 31, 1997.2 Background The parties submitted this case fully stipulated pursuant to Rule 122. We incorporate herein the stipulated facts. When petitioner filed his petition, he resided in Chicago, Illinois. Petitioner and His S Corporations Petitioner is a real estate developer. During the relevant years, he conducted his operations through multiple entities, including several wholly owned S corporations. In addition to Marc, these S corporations included: Lakeview Development of Barrington, Inc. (Lakeview); Pleasant Prairie Development, Inc. (Pleasant Prairie); and Silver Glen Development, Inc. (Silver Glen). For the year ending December 31, 1996, Marc sustained a loss of $792,752 (the Marc loss). At that time, petitioner had zero adjusted basis in Marc. Consequently, even though the Marc loss was allocable to petitioner, see sec. 1366(b), he was unable to deduct it in 1996, see sec. 1366(d). The Marc loss carried over 1 All section references are to the Internal Revenue Code in effect for the taxable years in issue. All rule references are to the Tax Court Rules of Practice and Procedure, as amended. 2 The deficiency for 1994 results from respondent’s disallowance of a carryback from 1997.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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